1. Revocation of the first instance judgment.

2. The instant lawsuit shall be dismissed.

3. The total costs of the lawsuit shall be borne by the defendant.

We examine the legitimacy of the instant lawsuit.

When an administrative disposition is revoked, such disposition shall lose its validity, and no longer exists, and a revocation lawsuit against a non-existent administrative disposition shall be unlawful as there is no benefit of lawsuit.

(2) In light of the aforementioned legal principles, the Defendant’s claim for correction as stated in the purport of the claim on September 9, 2019 is revoked, and the Defendant rendered a decision to refund KRW 17,742,660 out of the amount of tax that was paid to the Plaintiff upon correcting the amount of tax paid to the Plaintiff (i.e., refund KRW 17,698,890 (i.e., refund KRW 17,698,890). As such, the instant lawsuit is against an administrative disposition no longer effective, and thus, became invalid due to the lack of legal interests.

Thus, the lawsuit of this case shall be dismissed by the illegality of the judgment, and since the judgment of the court of first instance differs from this conclusion, it shall be revoked, and the lawsuit of this case shall be dismissed. It is so decided as per Disposition by the defendant under Article 32 of the Administrative Litigation Act as to the burden of litigation costs